Process for Disclosure and Role of COI Committee
Conflict of interest annual disclosures can now be completed via the Activities, Interests, and Relationships (AIR) online module. Please consult the detailed guide for completing the annual disclosure process. In addition, below are answers to some frequently asked questions.
What is the deadline for completing the annual disclosure process?
The deadline for completing Annual Disclosures has been moved to September 30th. This revised timeframe reduces the burden of end-of-the-year administrative tasks, and better aligns with the intent of the disclosure process to be forward thinking (e.g., you are asked to disclose current activities and those anticipated over the next year). A reminder letter will be sent out to the Campus Community at the start of the Fall semester.
What happens once I complete the disclosure process via AIR?
You should receive an email indicating that your disclosure has been received. The next steps depend on the content of your disclosure:
- If you answered “No” to all questions, then your annual disclosure process is complete.
- If you answered “Yes” to any questions, you will receive a follow-up email indicating whether additional steps (e.g., review by the COI Committee, creation of a management plan) are needed.
- If you have a potential conflict that needs to be addressed immediately, please contact UNCG’s Conflict of Interest Official, Dr. Lisa Goble at 336-256-1173 or email@example.com.
How do I determine the status of my disclosure once I’ve submitted it?
You can check the status of your disclosure and review prior disclosures at any time by logging into AIR, locating the Disclosure Dashboard on the left side of the screen, and clicking on “My COI Disclosures”. Next, in the “Filter By” drop-down box at the top, select “All Disclosures.” All prior disclosures (including project-specific disclosures resulting from RAMSeS proposal submissions) will appear, organized under three tabs: Incomplete (awaiting completion by you); In Process (submitted but under review); and Complete.
Now that we are using the AIR system, what is the process for reviewing disclosures?
All disclosures will receive an initial administrative review by the Conflict of Interest Official in the Office of Research and Economic Development. Department Heads/Chairs and other supervisors will continue to play a key role in the determination process when a potential conflict of interest exists; they also will be given a summary report that indicates the Annual Disclosure status for individuals within their units. The Conflict of Interest Official will serve in a case management role, shepherding situations where a potential conflict of interest exists through the review process by coordinating communication and information, providing guidance on policy, and referring cases to the COI Committee when appropriate. For those with known conflicts and/or existing management plans, this also will allow for greater streamlining of the review process.
What is the COI Committee and what is their purview?
The main function of the Conflict of Interest committee is to review COI cases that relate to research and other forms of scholarship. The COI Committee primarily reviews COI cases related to externally funded projects. UNCG is required by federal regulations to evaluate, manage, and report conflicts of interest in instances where federal funding is involved. The COI Committee also may review research-related COI when external funding is not involved. This is most likely to happen when human subjects research is involved. This committee serves in an advisory role to the Provost’s Office and the Office of Research and Economic Development.
Members of the committee are selected to be representative of the disciplines, but also knowledgeable of the topic at hand (including the COI regulations of not only the UNC system and UNCG, but also multiple federal agencies). Staff in the Office of General Counsel, Office of Sponsored Programs, the Office of Research Integrity, the Office of Innovation Commercialization, and other offices provide additional expertise and consultation.
There are, of course, situations that arise related to COI and EPA employees that are not research related. For example, situations involving faculty who own or have an interest in outside businesses that could overlap with their UNCG responsibilities other than research (teaching or their administrative duties) would likely be handled differently. These “administrative cases” are typically reviewed at the administrative level (department chair, members of the Provost’s Office, general counsel, and members of ORED, depending on the situation) in conversation with the faculty/staff member
Questions should be directed to Lisa Goble, firstname.lastname@example.org or 336-256-1173.